ML20235C480
| ML20235C480 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 06/30/1987 |
| From: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8707090434 | |
| Download: ML20235C480 (7) | |
Text
l Portland General ElectricCcirvary David W. Cockfield Vice President, Nuclear June 30, 1987 Trojan Nuclear Plant Docket 50-344 License NPF-1 Ditector, Office of Enforcement U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington DC 20555
Dear Sir:
TROJAN NUCLEAR PLANT Reply to Notice of Violation Your letter of June 4,1987 forwarded a Notico of Violation and Proposed Imposition of Civil Penalty for violation of radiological control require-ments. Our response to this Notice of Violation and Proposed imposition of Civil Penalty, and a voucher in the amount of $50,000 for payment of the Proposed Civil Penalty are attached.
Sincerely, Attachment c:
Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. R. C. Barr NRC Resident Inspector Trojan Nuclear Plant Me, David Kish, Director State of Oregon Department of Energy Subscribed and sworn to before me this 30th day of Jun 1987.
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s' Trojan Nuclear Plant Director, Office of Enforcement Docket 50-344 June 30, 1987 License NPF-1 Attachment Page 1 of 6 REPLY TO NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Violations A.
Technical Specification 6.11 requires that procedures for personnel radiation protection shall be prepared consistent with the require-ments of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure.
Contrary to the above requirement, as of April 17, 1987, the licensee had not developed radiation protection procedures to ensure that survey methods and control techniques would limit the exposure to workers from highly radioactive particles such that compliance with the general provisions expressed in 10 CFR 20.1(c) and specific dose limits of 10 CFR 20.101 would be met.
B.
Technical Specification 6.11 requires that procedures for personnel radiation protection shall be prepared consistent with the require-ments of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure.
The licensee's Radiation Protection Manual specifies the radiation dosimetry requirements for personnel. Radiation Protection Proce-dure RP-109, Personnel Dosimetry Program, provides the details to ensure implementation of these requirements.
Section III.C.1.b states, in part, that extremity TLDs will be required when the extremity dose is expected to be five times greater than the whole body dose and the dose to the extremities is expected to exceed 1 rem for the quarter.
Contrary to the above requirement, on April 17, 1987, a radiation protection technician entered the upender trench to perform radiation i
surveys, an area with hot spots on the floor with exposure rates up to 22 R/hr and whole body exposure rates up to 1.0 R/hr, without the use of lower extremity personnel monitoring devices even though he had prior knowledge from previous surveys that the extremity dose could be expected to be 5 times greater than the whole body dose and the dose to the extremities could exceed 1 rem for the quarter.
C.
10 CFR 19.12 requires, in part, that all individuals working in or frequenting any portion of a restricted area, shall be instructed in the health protection problems associated with exposure to radio-active materials and precautions or procedures to minimize exposure.
The extent of these instructions shall be commensurate with potential radiological health problems in the restricted area.
4 Trojan Nuclear plant Director, Office of Enforcement Docket 50-344 June 30, 1987 License NpF-1 Attachment page 2 of 6 Contrary to the above, on April 13 and 14, 1987, about ten contract refueling crew workers were permitted to enter the refueltag cavity and refueling floor. areas without being instructed on the potential radiological health protection problems associated with exposure to highly radioactive fuel fragments even though the licensee was aware of the increased radiological health hazard from fuel fragments from an incident that occurred on April 9, 1987. In addition, during April 9-17, 1987, contract and facility radiation protection tech-nicians providing coverage for refueling cavity and refueling floor work had not been instructed in precautions or procedures to minimize their exposure and that of their coworkers.
D.
10 CFR Part'20,201(b) requires that each licensee make such surveys as (1) are necessary to comply with regulations in 10 CFR 20 and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present. As defined in 10 CFR 20.201(a), " survey" means an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials or other_ sources of radiation under a specific set of conditions.
1.
Contrary to the above requirements, on April 9, 1987, seven workers engaged.in reactor vessel stud removal and plugging operations were exposed to highly radioactive loose surface contamination (a smear from the outer layer of protective clothing from one worker appeared to indicate a level of 4.1 rad /hr beta and 180 mR/hr gamma) and no survey or evaluation was made to determine the extent of radiation hazard to portions of their bodies resulting from the presence of radioactive material on their clothing.
2.
Contrary to the above requirements, on April 9, 1987, a radiation protection technician, following the dispersal of significant quantities of radioactive material in and around the refueling cavity, measured a spot on the floor near the reactor head flange that indicated an exposure rate of 30 rad /hr beta and 1.0 R/hr gamma; and on April 10, 1987, a different radiation protection technician measured another spot on the floor near the reactor vessel flange which indicated an exposure rate of greater than 100 rad /hr beta and 30 R/hr gamma and no evaluations were made in either case to determine the radiation hazard to individuals Who had previously worked in this area.
3.
Contrary to the above requirements, on April 12, 1987, a radia-tion protection technician measured radioactive contamination IcVels on the knees of his outer 4ayer of protective clothing that indicated exposure levels of 1.0 R/hr gamma and no evalua-tion was made to determine the radiation dose to his leg.
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Trojan Nuclear plant Director, Office of Enforcement Docket 50-344 June 30, 1987 License NpF-1 Attachment page 3 of 6 4.
Contrary to the above requirements, on April 17, 1987, a radia-tion protection technician entered the refueling cavity and, upon exiting the upender trench, handled and otherwise manipulated his contaminated rubber shoe cover, which had an exposure rate of greater than 50 R/hr gamma at contact, and an evaluation of the radiation hazard to his hand and other portions of his body was not performed.
E.
10 CFR 20.401(b) requires, in part, that each licensee shall maintain records showing the results of surveys required by 10 CFR 20.201(b),
" Surveys". 10 CFR 20.201(b) requires that each licensee make or cause to be made surveys as:
(1) may be necessary for the licensee to comply with the regulations in 10 CFR 20, and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be precent.
1.
Contrary to the above requirements, as of April 20, 1987, the licensee failed to maintain a record of a wipe survey from a worker's outer layer of protective clothing on April 9, 1987 that appeared to indicate 4.1 rad /hr beta and 180 mR/hr gamma.
2.
Contrary to the above requirements, as of April 21, 1987, the licensee failed to maintain a record of a survey from the knees of a radiation protection technician's outer layer of protective clothing on April 11, 1987 that appeared to indicate 1.0 R/hr gamma.
Collectively, these violations have been classified as a Severity Level III problem.
(Supplement IV)
Cumulative Civil penalty - $50,000 - assessed equally among the violations.
Reply to Violations:
portland General Electric admits to the above violations and agrees to pay the cumulative civil penalty.
Reasons for Violations 1,
A lack of training on discrete radioactive particles for both radiation workers and Radiation protection Technicians.
2.
A failure of the Radiation protection Technicians to document the radiological surveys of work areas and the workers.
3.
A lack of the appropriate procedures to facilitate the work activities in areas with discrete radioactive particles.
Trojan Nuclear Plant Director. Office of Enforcement Docket 50-344 June 30, 1987 License NPF-1 Attachment Page 4 of 6 4.
A failure of the Radiation Protection Technicians to follow the procedures that were available concerning the documentation and evaluation of radiological surveys and measurements.
Corrective Actions Completed In a letter dated May 13, 1987 from David W. Cockfield to John B. Martin, several actions were discussed which had been taken or were planned for the improvement of radiological control performance. A summary of the corrective steps that have been taken is presented below.
Based on these completed actions, full compliance with the applicable radiological control requirements of Title 10, Code of Federal Regulations, Parts 19 and 20, Section 6.11 of the Trojan Technical Specifications, and the Trojan Radiation Protection Manual has been achieved.
A.
Improvements were developed in the radiological surveys of work areas and workers.
In addition, improvements were made on the control of worker exposure through the implementation of new Radiation Protec-tion Procedures that specifically address the survey and control of work activities in areas with discrete radioactive particles. These procedures instituted a zonal control program and were implemented by May 1, 1987.
B.
The radiological control program associated with extremity monitoring of workers was improved by revision (by May 7, 1987) of the Radiation Work Permits to require extremity dosimeters for worker activities where discrete radioactive particles may cause extremity exposure.
C.
The training of radiation workers for work activities in areas with discrete radioactive particles was revised to include the zonal concept of radiological control. This training was given to all radiation workers by May 2, 1987. Workers who had not received the training were restricted access to radiological areas until training was completed.
D.
The initial training for Radiation Protection Technicians on radio-logical controls for discrete radioactive particles was completed by April 29, 1987. Additional training is being prepared for Radiation Protection Technicians using information gained from the 1987 refueling outage. This additional technician training will be completed by September 30, 1987.
E.
Radiation exposure investigations have been performed on all workers involved with work activities associated with the reactor cavity and the reactor vessel head during the period of April 9-17, 1987. The initial radiation exposure ir.vestigations on the workers with the highest probability of significant additional exposure was completed by May 13, 1987. This initial group included the worker who entered
'g4 Trojan Nuclear Plant Director, Office of Enforcement
, Docket 50-344 June 30, 3987 License NPT-1 Attachment Page 5 of 6 the upender sump, the workers with high levels of radioactive con-tamination on their protective clothing and workers who may have received additional extremity exposure from working on the reactor vessel. head and studs. 'In addition, the radiation exposure investi-gations were expanded to include other workers in the Containment who may have come in contact with discrete radioactive particles. These additional investigations and the documentation of all the investiga-tions have been completed. The results of these exposure investiga-tions have shown that no worker received an exposure in excess of the Nuclear Regulatory Commission quarterly radiation exposure limits of Title 10, Code of Federal Regulations, Part 20 " Standards for
~;
Protection Against Radiation".
The maximum. individual whole body, skin, and extremity exposures determined by these investigations were 1.2 rem, 4.6 rem and 16.5 rem, respectively.
In addition, bioassay measurements were made for all the involved workers and none of these measurements showed more than one percent maximum permissible body burden to any individual.
F.
An investigation'of radiological control performance has been con-ducted by the portland General Electric Performance Monitoring / Event Analysis Group. This investigation included determination of the possible origin and history of fuel-type contamination material. A draft report on this investigation was completed by late May 1987 and q
a final report will be issued by July 1, 1987.
Corrective Actions to be Taken In addition to the completed actions noted above, the following corrective actions will be taken to further enhance the radiation
. protection program at the Trojan Nuclear Plant.
A.
By July 1, 1987, a Personnel Protection Review Committee will be implemented to review radiation protection practices and to ensure that appropriate corrective actions are taken for radiation protection occurrences.
B.
By July 1, 1987, a Radiation Event Report will be implemented which will ensure that radiation protection problems receive adequate review, evaluation, corrective action, and management attention.
C.
Two additional health physicists will be provided for the Corporate and Plant radiation protection organizations to improve technical capability and to ensure proactive support of the radiological control program.
These two individuals, who will initially be contract personnel, will be added by September 1, 1987.
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e Trojan Nuclear Plant Director, Office of Enforcement Docket 50-344 June 30, 1987 L conse NPF-1 Attachment j
Page 6 of 6 D.
The Radiation Protection Procedure for dosimetry control will be revised by September 30, 1987 to provide more explicit direction in the use and requirements of extremity dosimetry.
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E.
Training on radiological controls for discrete radioactive particles will be incorporated into the biannual retraining cycle for Radiation Protection Technicians and in the training program for contract Radiation Protection Technicians by December 31, *iG87.
NCD/kal 1840W.687